Case Summary (G.R. No. 234691)
Employment Background
In July 1990, Bernabet A. Maala began her employment as a casual employee at the NCWDP as a clerk II. In June 1995, she failed the Social Worker Licensure Examination, receiving a grade of 67.40%. Despite this, Maala applied for a permanent position as clerk III, claiming to have passed the examination with a grade of 76.25% and submitted what were later found to be falsified documents.
Administrative Complaint
The CSC issued a memorandum in April 1996, reporting that Maala misrepresented herself as a licensed social worker. This prompted the NCWDP to file an administrative complaint against her, alleging that she submitted spurious documents to support her application for a promotion, which led to Administrative Case No. 96-05-65.
Respondent's Defense
In her defense, Maala claimed she acted in good faith and was misled by a so-called 'fixer,' Armi Liguid, who assured her that her failing examination grade could be reconsidered. She maintained that she had no intentions of dishonesty and submitted documents under the belief that she had legitimately obtained the necessary qualifications.
CSC's Resolution
Following the investigation, the CSC issued a resolution on June 3, 1998, finding Maala guilty of dishonesty resulting from the falsification of official documents. As a consequence, she was dismissed from service with a perpetual disqualification from holding public office or taking future civil service examinations. Maala's subsequent motion for reconsideration was denied by the CSC.
Court of Appeals' Decision
Maala appealed the CSC's decision to the Court of Appeals, which ruled in her favor on April 6, 2004. The Appellate Court found her to have acted in good faith and reversed the CSC's resolutions, exonerating her of the charges of dishonesty and falsification.
Supreme Court's Review
The CSC then contested the Court of Appeals' ruling in the Supreme Court, arguing that the lower court erred in finding Maala’s actions as being in good faith. The Supreme Court observed that the determination of good faith is fundamentally a factual question typically beyond its review; however, given the conflicting findings between the CSC and the Court of Appeals, a review was warranted.
Good Faith Analysis
The Supreme Court elaborated on 'good faith' as a state of mind c
...continue readingCase Syllabus (G.R. No. 234691)
Case Overview
- The case involves a petition for review on certiorari filed by the Civil Service Commission (CSC) against Bernabet A. Maala.
- The petition challenges the Decision dated April 6, 2004, and the Resolution dated September 6, 2004, of the Court of Appeals in CA-G.R. SP No. 49176, where Maala was exonerated of administrative charges of dishonesty and falsification of official documents.
Background Facts
- Bernabet A. Maala began her employment as a casual employee at the National Council for the Welfare of Disabled Persons (NCWDP) in July 1990, as a clerk II.
- In June 1995, Maala took the Social Worker Licensure Examination and received a failing grade of 67.40%.
- In October 1995, while applying for a permanent position as clerk III, Maala inaccurately claimed in her Personal Data Sheet that she was a licensed social worker with a passing grade of 76.25%.
- She submitted several documents in support of her application, including a certificate from the Professional Regulation Commission (PRC) and documents allegedly related to a successful petition for reconsideration regarding her licensure examination results.
Allegations and Administrative Proceedings
- The CSC was alerted to the misrepresentation by Director Arnel G. Delmonte of the CSC Field Office, leading to an administrative complaint against Maala for dishonesty and falsification of official documents.
- The complaint asserted that Maala had submitted spurious documents and misrepresented her licensure status, which resulted in her appoi